Lesley Griffiths AM is Welsh Government’s Cabinet Secretary for Environment and Rural Affairs. On 18th October during Assembly questions she was questioned about National Parks and AONBs. In her answer she referred to concerns raised recently as ‘a lot of mischief-making’. This dimissive comment reveals a serious situation. The concerns which the minister brushed aside as ‘mischief-making’ don’t come from crackpots. They come from respected organisations across Wales, and from thoughtful scrutiny of the ‘Future Landscapes Wales’ proposals and process for which she is responsible. We provide a few examples of those concerns below.
The minister’s flippant comment suggests a lack of interest in the future of our National Parks and AONBs, unless she believes that she knows better than the organisations listed below. It is time for proper oversight and governance of the Future Landscapes process. The Future Landscapes report is shoddy and ill-conceived.
The finest landscapes of Wales are too important to be put at risk by the inadequate and illegitimate Future Landscapes process and its flawed report.
What the Royal Town Planning Institute Cymru has to say:
‘With the Future Landscapes Wales Working Group tasked with considering and advising on the way forward with the Marsden Report, it is difficult to understand how these key considerations, linking the Sandford Principle, the Silkin Test and the planning functions of National Parks came to be absent from the Future Landscapes: Delivering for Wales report. Accordingly, it would not be reasonable to accept that this report could provide the blueprint for the future of our landscapes. With such critical omissions, there are concerns that the Future Landscapes: Delivering for Wales report could expose the future of our designated landscapes to unacceptable risks.’ (document here:RTPI Cymru Response Natural Resources (1))
What the International Union for the Conservation of Nature’s UK Assessment panel has to say:
‘Our panel provides independent advice on whether areas in the UK meet IUCN’s standards and can therefore be recognised as protected areas. In this context, the new report raises serious concerns. It conspicuously fails to endorse the core recommendations from Marsden about the primacy of conservation, and sets out a questionable view of these designated areas as “catalysts for regional development”. If acted upon, the recommendations in the Future Landscapes report would make it impossible for the panel to continue to accord international recognition to Wales’s NPs and AONBs as protected areas.’ (document here: IUCN Future Landscapes.final (1))
What RSPB Cymru has to say:
‘However, our gravest concern is that the [Future Landscapes] report explicitly recommends the need to create new laws that will re-purpose National Parks and AONBs, and even worse, it presents this as the view of the working group. This is absolutely not RSPB Cymru’s view and we believe it was not the view of the working group either. The group did not identify the current legal objectives of designated landscapes as a key barrier to sustainably managing our natural resources, but rather the group proposed that the focus should be on using the frameworks set out by the Environment Act and Well-being of Future Generations Act. We do not recall the group discussing the Welsh Government’s new proposal to legislate on the purposes (i.e. the objectives) of National Parks and AONBs in any detail at all. This means that we feel the published report does not accurately represent our views.’ (link to RSPB post)
What Natural Resources Wales, the government’s own statutory advisory body has to say in its response to the recent consultation;
‘Instigating the most fundamental change to the National Parks and AONBs (Designated Landscapes) in nearly seventy years requires great care to ensure the policy intention is achieved.
Any changes to the purposes of the Designated Landscapes would require a careful reconsideration of the Sandford Principle to ensure continuity of the precautionary principle (and its SMNR Principles equivalent: Preventative, Long-term, Evidence-based) to mitigate against any potential loss of natural beauty or landscape quality.
The National Parks and AONBs are often cited among the best examples that we currently have of pursuing the sustainable management of natural resources in highly sensitive areas. There is no evidence to suggest that the existing statutory purposes are a barrier to implementing the sustainable management of natural resources and therefore our view is that legislation to change the statutory purposes of National Parks and AONBs is unnecessary. Instead, NRW believes effort would be better directed on supporting the Designated Landscapes to manage our natural resources.
As the designating authority in Wales, NRW is mindful that changes to the purposes of National Parks and AONBs could have unintended consequences such as: 1. the potential dilution of protection, threatening ecosystem resilience and adaptability; 2. a legal misalignment for existing designations, with the original mandate for the legal designation being broader than the proposed revised purposes; 3. an incongruity in relation to the statutory designation process, which along with other legislative provisions, would also require major and far reaching amendment to primary legislation.’
And from Professor Terry Marsden, an expert on environmental planning and policy in Wales, in a letter to Assembly Members in September: ‘It is a matter of some urgency that the designated landscapes review process takes on board the clear feedback from participants and stakeholders.’
Serious concerns over the Future Landscapes Wales proposals have been expressed by:
International Union for Conservation of Nature UK Assessment Panel
Royal Town Planning Institute
Wildlife Trusts Wales
British Mountaineering Council;
Youth Hostelling Association
UK Environmental Law Association
Wales Environment Link
Alliance for Welsh Designated Landscapes
Cymdeithas Eryri the Snowdonia Society
Friends of Pembrokeshire Coast National Park
Brecon Beacons Park Society
Cambrian Mountains Society
Open Spaces Society
Campaign for National Parks
CPRW Brecon and Radnorshire
…and many more…